Higher-corruption risk functions


Higher-corruption risk functions in ACT Government

The ACT Government has responsibility for a diverse range of functions, undertaken by a variety of entities. The Commission has compiled the following list of functions which are performed by, or on behalf of, the ACT Government which are potentially vulnerable to corruption, particularly if appropriate measures are not adopted to mitigate corruption risk.

These functions have been identified during Commission investigations, and through an analysis of the work of other integrity and anti-corruption agencies throughout Australia, as being higher-corruption risk functions. These functions may be more susceptible to corruption on the basis that they all involve (or have the potential to involve) to varying degrees, high levels of autonomy and/or discretion, coupled with limited accountability and/or oversight.

Public sector entities, and those entities performing functions for or on behalf of the ACT Government, may wish to consider the functions listed below as a starting point in identifying potential vulnerabilities and where to target prevention measures to best mitigate the threat of corruption.

Important note:

This should not be considered a comprehensive or exhaustive list of higher-corruption risk functions. Entities may identify other at-risk functions requiring specific treatment or prevention measures.

Entities should consider their corruption risk holistically across their organisation at both the operational and strategic levels. Entities should also consider the circumstances in which functions are performed, including the specific environmental, contextual and people factors relevant to their operations. These factors will vary over time and place. Prevention measures should be reassessed periodically to ensure they remain fit for purpose.

Higher-corruption risk functions

Receiving cash payments for the provision of government services
Planning, managing or deciding on large scale procurement activity
Inspecting, regulating and monitoring compliance with, or adherence to standards and requirements
Issuing qualifications or licences to individuals, groups or other entities which demonstrate proficiency in, or enable the undertaking of, certain activities
Allocating monies or other benefits, including funds, grants, subsidies, financial assistance, welfare or concessions
Issuing, or reviewing the issue of, fines or other sanctions
Assisting or caring for vulnerable people
Making decisions or judgements concerning individuals, or deciding on disputes involving multiple parties
Approving land rezoning or land development applications
Having regular contact or interactions with criminal or higher-risk entities while performing normal duties
Having regular interactions with the private sector, other than for the routine purchasing of goods and services
Having access to, or being responsible for dispensing, controlled substances

Any function(s), duties or projects where:

  • public officials are afforded high levels of discretion in decision making
  • oversight is limited or not possible or where the nature or location of duties limits opportunities for direct accountability
  • time and resourcing pressures require modification or non-adherence to normal due diligence requirements
  • public officials are detached from their agency’s usual integrity measures (e.g. reporting and support measures) for an extended period
  • contemporary skills and knowledge obtained while performing public duties is highly valued and/or would provide significant competitive advantage to commercial entities
  • expectations/requirements regarding proper conduct/process are vague, ambiguous and/or may be subject to a significant degree of varied interpretation and/or discretion (grey area) or “wriggle room"
  • a public official is afforded additional access (for example ICT administrators, payroll officers) to systems and/or information.